IN THE COURT OF SESSIONS JUDGE & JUSTICE OF PEACE DADU.
Crl. Mis Appln NO. oF 2015
Ghulam
Abbas S/o Ghulam Qadir by caste soomro R/O Village ismail Achra Taluka &
District Dadu……………………….....Applicant.
Versus
1.
The
SSP Dadu.
2.
SHO
P.S A. Section
3.
SHO
Rukkan
4.
Amjad
Ali s/o Mohammad Yousif R/O Police Line Dadu……………………….…………………………………...Opponent.
APPLICATION UNDER SECTION 22 B-C(II) CR.PC
That the applicant named above begs to
submit as under:.
1.
That the applicant resides
at the above address peace loving & law abiding citizen of Islamic Republic
of Pakistan having good reputation and soft record in the locality.
2.
That the private
opponent No.4 is husband of applicants sister, has dispute of Family with the applicant
party. Several times different notables has made FAISLA, he has admitted his
mistakes but after lapse of few days he repeats again & again same immoral
activities. (Copy of such
FAISLA is attached).
3.
That the private opponent is
influential person having good terms with local MPA, MNA & Police.
4.
That on 05-10-2015, the applicant along with his house
inmates were present in his house, it was about 5:00 PM, the opponent no 4
entered into the house of applicant and said he has managed CNIC of Mst.
Rizwana in collusion with NADRA employee in name of his brothers wife, now I
will implicate you in false cases, and gave threats of dire consequences to
withdraw from the Family suit of Maintenance filed by the sister of applicant.
5.
That the opponent no 4 is smoker, Drinker and made the life
miserable and blackmail to the applicant
to put pressure and keeps illicit relation with other ladies, so he drove out
his wife from his house, But in rebuttal he filed Habeas Corpus Appl. No
169/2015 for wrongful confinement of his children & wife, His wife was
produced before honorable court she denied wrongful confinement, hence the application
was disposed of.
6.. Then after the opponent filed FC
Suit No 11/2015 for Restitution of Conjugal Rights same is pending in Family
Court , but applicant is man of fraudulent person and he in order to blackmail
files application again & again against the applicant.
7. That
the applicant approached to the SHO A Section Dadu, and informed him about the
facts and asked for protection but he in collusion of private opponent did not
pay any heed to it even issued threats to the applicant not to come at P.S,
otherwise, he will register case against
him.
. 8. That the applicant seeing no other
alternate remedy
file this application before this honorable
court With following
prayer.
a: That this
honorable court may be pleased to prevent
the private opponent not to come in
the house of applicant.
b: That this honorable court
may be pleased to direct the
opponent No.1 to 3, not to Register false FIR
against the applicants
other family members, and not to harass them
at the instance of
private opponent.
c: That this Honorable court
may be pleased to direct the
opponent No. 1 to 3 to provide legal &
lawful protection to the
applicant and his family in accordance with law.
d. Any Other
relief which this honorable court may
deem fit and proper under the
circumstances of the case may be
granted to the applicant.
Dated: Applicant
Ghulam Abbas Soomro
Advocate
For the
applicant
.
IN THE COURT OF SESSIONS JUDGE & JUSTICE OF PEACE DADU.
Crl. Mis Appln NO. oF 2015
Ghulam
Abbas S/o Ghulam Qadir by caste soomro R/O Village ismail Achra Taluka &
District Dadu……………………….....Applicant.
Versus
1.The
SSP Dadu.
2.SHO
P.S A. Section
3.
SHO Rukkan
3. Amjad Ali s/o Mohammad Yousif R/O
Police Line Dadu……………………….…………………………………...Opponent.
A
F F I D A V I T
I, Ghulam Abbas S/O Ghulam Qadir
by caste Soomro Muslim, Adult,
R/o Village Ismail Achra Taluka Dadu,
District Dadu, do hereby state on oath as under:-
1. That I am applicant/accused in
the above matter and know the facts very well.
2. That I am innocent and has been
falsely implicated due to admitted dispute over the boundary of house.
3.
That the
accompanying application of 22 B.C (ii) and instant affidavit have been drafted
under my instruction and hence the contents are not repeated.
4. That whatever is stated above is true
and correct to the best of my knowledge and belief.
Dadu.
Dated. Deponent
I know the deponent
Advocate
Mujjan Ali Panhwar
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